Inspectors are retroactively applying this factor to emissions from the last cycle year and advising facility operators that they should re-calculate and correct for the quarter already reported for this year and the reporting periods going forward using the 68 degree base. They are not imposing any enforcement action due to this retroactive “correction” and say that an advisory letter stating the new policy will be sent out soon.
This action of “correcting” the emissions will result in the overall emissions from the RECLAIM program to be higher across the board for last year and this year. If the RECLAIM program were to be discontinued – as the SCAQMD has been suggesting they might do – they should be able to show a greater reduction in emissions from the switch to command-and-control regulations then they would previously after this temperature correction. We believe this to be evidence that the district is getting serious about ending RECLAIM and forcing those facilities to come into compliance with current BACT standards.
The new temperature “correction” factor is 1.015. Emission calculations should be multiplied by this factor only for those who use their gas bills or Envoy for calculations. If you have a temperature and pressure corrected meter set to a base temperature of 68 degrees, then it should not be included. Emissions from rule 219 exempt equipment does not need to be calculated using the factor.
If you have questions or need more information, give us a call at 562-495-5777.
Blog post by Kimba Anderson, Senior Associate Consultant